The FCC certification process for products with wireless features can be complicated and daunting. Increasingly, customers are expecting wireless features, yet many manufacturers hesitate because of the uncertainty of the certification process. This article discusses the FCC certification process for the United States and shows that it is not as bad as it may seem. Other countries have different processes and procedures, but that is beyond the scope of this article.
The Federal Communications Commission (FCC) regulates radio frequencies in the United States. They make sure that wireless broadcasters like TV, radio, cellular, garage openers, toys, military and first responders can share the wireless spectrum without interfering with each other. Some broadcasters are licensed to broadcast on a specific spectrum, such as a radio station. A radio station can be licensed to operate at 100.3MHz in a region and the FCC regulations prevent someone else from using that spectrum.
The FCC allows unlicensed broadcasts as well, but they are subject to regulations to prevent interference. The FCC rules for unlicensed broadcasting from below 1MHz to in excess of 32GHz are included in CFR 47 Part 15. It is broken into individual sections that govern the use of specific frequency bands. For example, section 15.249 covers the 902-928MHz band. In this frequency range, a user is allowed to transmit any analog or digital signal they desire so long as the stipulations governing allowed output power, harmonics and occupied bandwidth are met. Other sections are not so accommodating. For example, in the 260-470MHz band, the FCC considers not only RF factors but also the intended function and application.
The FCC requires any device that radiates RF energy to be tested for compliance with the FCC rules. As stated earlier, Part 15 deals with the operational aspects and requirements for devices that emit RF energy and are to be operated without the end user needing a license. Part 2 deals with issues of marketing and authorization and includes details on the certification and approval process.
To help gain a better understanding of going wireless, let’s break down the Certification and Approval process into eight steps.
Eight Steps in the FCC Certification Process
1. Choose the Optimum Operating Frequency
2. Component Selection
3. Build Production-Ready Prototypes
4. Prescreen and Optimize
5. Lab Selection
7. Send the Production-Ready Product to an FCC Authorized Testing Facility
To figure out which operating frequency is best for your product, it’s necessary to weigh both technical and legal issues. First, you’ll want to have a clear understanding of which frequencies are legally available. Then you can choose a specific frequency based on technical issues, like range, propagation, antenna length, power consumption and potential interference.
Once you’ve chosen a frequency of operation, the RF section and antenna must be carefully designed and optimized to comply with the allowed power and harmonic limitations imposed by Part 15. If you’re using a Linx module, this is much easier to do, but it’s still important to recognize that the antenna and layout play key roles in your product’s legal operation.
Once you’ve selected a frequency of operation and a suitable RF stage, you’ll want to move from concept breadboard prototypes to a production-ready model as soon as you can.
When your wireless product is finished, its output power and harmonics should be checked to ensure that the RF stage is both optimized and Part 15 compliant. You’ll need a spectrum analyzer and calibrated antennas for this. If you don’t have access to these instruments, consider prescreening. Linx has partnered with a test lab that offers these services at a discount to Linx customers. The process can result in a cost savings over formal testing and provides you with an opportunity to maximize product performance.
The FCC certification process requires that final product testing be conducted by a registered testing facility. You can find a list of labs on the FCC website. The quality and competence of labs varies widely, and labs appearing on the list are independent. Linx is happy to recommend competent facilities; however it is the sole responsibility of applicants to choose a test lab capable of measuring their specific device.
Once you’ve picked a lab you must determine the extent of services they’ll provide. Our advice? Have the lab do as much as possible. Taking time to understand the subtleties of the filing process in the middle of trying to get a product to market is a bad idea. Saving a few dollars trying to do things yourself may end up costing you more in the end, and in some cases may even jeopardize your ability to receive approval.
When your product is complete and ready for testing, a Federal Registration Number (FRN) must be obtained. This is free and can be obtained online in just a few minutes on the FCC website. Next, request a grantee code from the FCC, which can also be done online on their site. The grantee code is $60 and must be paid within 30 days of the application.
Once your product is in its finished form, exactly as it will be produced, testing should be conducted by an accredited laboratory. In most cases, it’s not necessary to be present during the testing and the lab will prepare the filing paperwork.
The testing usually takes less than two weeks depending on the lab’s backlog and schedule. So, it’s a good idea to call the lab in advance to let them know about your project and secure a spot in their testing schedule. The test lab will need a number of items to complete the filing, which often include:
- A letter appointing the test lab as your technical agent for certification. The lab will provide a sample letter.
- The FCC ID Number of the unit. The first 3 or 5 characters are the grantee code. The rest are up to the applicant, up to 14 characters.
- A sketch of the location of the FCC label on your unit as well as a sketch (with dimensions) of the label itself.
- A block diagram of the unit showing all clock oscillators and their frequencies of operation. The signal path and frequency should be shown at each block.
- Full schematic diagram
- The user’s manual
- A brief, non-technical description of the product and its operation
- A product sample for testing and photos
Other letters may also be required. The applicant can request confidentiality so that the product schematics and block diagrams will not be posted on the FCC’s web database. The FCC does need this information to issue a grant, but they do protect intellectual property if requested to do so.
Something that should be noted is the importance of the labeling. This often becomes an issue because it is more important that it may seem at first. Products should be labeled as required by Part 2.925 and 2.926 as well as Part 15.19 or otherwise prescribed by the FCC. This includes labels on the product as well as statements that need to be included in the user’s manual. In addition, the label must be permanently fixed to the product and last the expected life of the product. Paper labels are not allowed, so other materials, inks, printing processes and adhesives must be evaluated.
It is highly recommended that these sections be reviewed early so that the entire certification is not stalled waiting on a correct label design. Visit the FCC website for additional information on labeling.
8. The Filing Process
Certifications were once issued by the FCC directly, but independent testing laboratories are now allowed to issue certifications through the Telecommunication Certification Body (TCB) program.
The filing process is usually done through the test lab as part of their service. The lab will compile the test reports, photographs, and other items mentioned above. The TCB will review all application materials and, if the device conforms to the requirements, they will upload this information to the FCC. After they receive the report, the FCC will add the product and the ID number to their database and their website and issue a Grant of Equipment Authorization. At this point, the product can be legally marketed and sold.
Congratulations! You have completed the FCC certificaton process and your product is now ready for the masses.
This blog post has only covered the FCC certification process which is for the United States. The process for international certifications varies widely as does the cost. For example, the requirements for Industry Canada are very close to those for the United States, so adding a Canadian certification is generally not much more expensive than the U.S. alone. The European Union has harmonized requirements across all European countries, meaning one testing effort can gain certification for all of Europe. However, the test requirements are much more involved than for the U.S. This equates to more expense. There is no filing with Europe, just a declaration by the manufacturer that the product conforms to all of the requirements. This declaration needs to be backed up by a test report should it ever be requested by Europe.
Most countries tend to follow the same rules as either Europe or the U.S., however there are some differences. Many countries require testing to be done in their country and all of them require a representative within the country as a point of contact. This representative can be a distributor, business partner or family friend. The regulatory agencies simply want a point of contact within the country that they can reach if they have any questions or need a sample product for verification.
Regardless of the countries, you should become aware of the requirements for each before you market your product. The certification process is a lot of paperwork and varying cost, but the addition of wireless features can take a product to that next level of success.
The FCC has made an allowance for modular certification. A radio module can be tested for compliance with the rules and then included in multiple end products without having to undergo the full amount of testing. This can save a lot of time and money, but does come with some requirements. The module itself has a number of requirements to ensure that it will operate consistently across multiple products and installations.
The designer integrating the module into an end product also has requirements. The antenna that is used in the product must be an antenna that was tested with the module. This includes all cables and connections between the module and antenna. A different antenna can be used with the radio, but the modular certification will not carry over and the end product will have to go through the full FCC certification process.
Also, there is no modular certification for a receiver. A transmitter or the transmitter in a transceiver can be certified, but the receiver must be tested in the end product. Fortunately this “unintentional radiator” testing is much faster and cheaper than the transmitter or “intentional radiator” testing, but it must still be done before the product can be marketed.
As the number of wireless products has grown over the years, the process for certification has become much more streamlined. We hope that this article has eased the concerns about going through the FCC certification process and prepared you for an exciting new world of opportunities. If you have any additional concerns or questions, you can contact Linx and speak to an applications engineer or contact a test lab.